Ofcom Plan of Work 2022-23 Consultation

Ofcom has published their proposal for their Plan of Work for 2022-23.

The deadline for responses is 9 February 2022.

This is a good opportunity to look at and challenge the priority areas that Ofcom is proposing.

A quick read indicates that the focus is once again on Consumer engagement, rather than building support and resources for Citizenship.

It outline the continuing reviews of Public Service Broadcasting, the BBC, Media Literacies, and Media Pluralism.

What would be the preferred method for reviewing the plan, making observations and drafting a responce?

https://www.ofcom.org.uk/__data/assets/pdf_file/0023/229640/Consultation-Ofcoms-proposed-plan-of-work-2022-23.pdf

Have I read the proposed Ofcom work plan correctly?

All the way through the document it mentions ‘citizens’ a total of six times, and ‘consumers’ a total of forty-four times.

The general duties of Ofcom defined in the Communications Act 2003 are:

3(1) It shall be the principal duty of OFCOM, in carrying out their functions—

(a)to further the interests of citizens in relation to communications matters; and

(b)to further the interests of consumers in relevant markets, where appropriate by promoting competition.

Why is Ofcom not giving equal weight in its operations to the needs of citizens?

It’s well worth reading the Communications Act 2003, and the role given in legislation to Ofcom

https://www.legislation.gov.uk/ukpga/2003/21/section/3

"It shall be the principal duty of OFCOM, in carrying out their functions—

(a)to further the interests of citizens in relation to communications matters; and

(b)to further the interests of consumers in relevant markets, where appropriate by promoting competition."

Which is later qualified:

“citizens” means all members of the public in the United Kingdom;

“communications matters” means the matters in relation to which OFCOM have functions;

[F4“end-to-end connectivity” has the meaning given by section 74(3);]

“general duties”, in relation to OFCOM, means—
(a) their duties under subsections (1) to (5); and
(b) the duty which, under section 107(5), is to rank equally for the purposes of subsections (6) and (7) with their duties under this section;

“relevant markets” means markets for any of the services, facilities, apparatus or directories in relation to which OFCOM have functions.

It’s clear that Ofcom has not been advocating or representing the interests of citizens, and only the interests of consumers. So for those who are not considered economically active, or who are socially insecure, and are not able to engage in consumer-type activity, Ofcom is making no provision for universal access o services.

For example, the present push for Small Scale DAB is predicated on the basis that Ofcom think that £20 for a receiver is affordable, while not taking into account the power requirements, the reception limitations, the portability, or the availability of DAB sets.

There is still a high demand from community radio stations for use of FM and AM frequencies, and Ofcom is shutting this down by forcing through SSDAB.

We have a chance to challenge this in the Work-Plan consultation and insist that Ofcom re-opens FM and AM licencing.

Who else should we invite to take part in this discussion?